Modelo 720: Declaration of Foreign Accounts and Assets

What modelo 720 is, in plain words

Modelo 720 is a report to the tax agency (AEAT) on what a Spanish tax resident holds abroad. The full name of the form is “Declaración informativa sobre bienes y derechos situados en el extranjero”. It combines three separate obligations: reporting accounts at foreign banks; securities, insurance and annuities; and real estate. Legal basis: additional provision 18 of Ley 58/2003 (LGT), articles 42 bis, 42 ter and 54 bis of Real Decreto 1065/2007; the form was approved by Orden HAP/72/2013 [1][2][9].

The return itself does not create any tax: AEAT states that this obligation is not linked to any particular tax [7]. Tax on income from these assets, such as interest or rent, is calculated in modelo 100 [10]. Cryptocurrencies are not included: there is a separate form, modelo 721, for virtual currencies [9].

Who must file modelo 720

The obligation depends on tax residence, not on the type of residence permit. It is filed by tax residents: individuals and legal entities, permanent establishments of non-residents and entities under article 35.4 LGT. For an individual, residence is determined under article 9 of Ley 35/2006: more than 183 days in a calendar year or the main centre of economic interests in Spain, plus the family presumption [1][10]. More: tax residence in Spain.

The group of people who must file is wider than owners. Authorised persons, beneficiaries, persons with power of disposal over an account and ultimate owners under Ley 10/2010 must also file. Anyone who was a holder (titular) at some point in the year but lost that status before 31 December reports the information as at the date the status ended [1].

Business owners and companies that keep accounts under the Código de Comercio and record these assets individually in their books do not file (article 42 bis, 4.c, and the equivalent points) [1]. According to AEAT’s guidance, people under the special regime of article 93 of Ley 35/2006 (Beckham law) do not file the return, because they do not pay tax on their worldwide income. Their family members are not automatically exempt: they file if they are tax residents and exceed the threshold [7].

Three asset groups and the €50,000 threshold

The €50,000 threshold applies to each group separately. If it is exceeded, all assets in that group go into the return, not just the amount above the threshold [1]. No information on accounts has to be filed if neither the balances on 31 December nor the average balances for the last quarter exceed €50,000 [1]. Accounts opened at foreign branches of Spanish banks and already reported by the bank are excluded from the accounts group (article 42 bis, 4.d) [1].

Filing deadline and how to file in later years

The return is filed from 1 January to 31 March of the year after the reporting year. For assets held on 31 December 2025, AEAT set the window from 1 January to 31 March 2026. If online filing is impossible for technical reasons, four more calendar days are allowed [6]. You can file using the online form or by uploading a file [9]. As of 2 October 2026, AEAT has not yet published the window for assets held on 31 December 2026: under articles 42 bis, 42 ter and 54 bis it is again from 1 January to 31 March 2027 [1].

A new return is needed if the value of a group has grown by more than €20,000 compared with the last return filed. For accounts, both figures are compared: the balance and the average balance. You also have to file when you stopped being the owner of an asset during the year [1]. If you became a tax resident in the middle of the year, the IRPF period is still the calendar year, and the obligation for that year is assessed on 31 December. The details of the first year depend on the dates; this is a question for a tax adviser.

Modelo 100 and modelo 720: what’s the difference

Modelo 100 is the annual IRPF return (Impuesto sobre la Renta de las Personas Físicas): it calculates the tax on the calendar year’s income and gives an amount to pay or a refund. Modelo 720 only reports that you hold assets abroad [1][11].

Table data: [1][5][6][11]. The obligations do not depend on each other. If the amount in a foreign account is below the threshold, modelo 720 is not needed for accounts, but the interest on it is still part of the resident’s worldwide income in modelo 100 (article 2 Ley 35/2006) [5]. Anyone entitled to the deduction for international double taxation files modelo 100 in any case (article 96.4) [5]. How tax on the same income is taken into account in two countries: double taxation between Russia and Spain.

A person under the article 93 regime of Ley 35/2006 (modelo 149) files the annual return on modelo 151 instead of modelo 100 and, according to AEAT’s guidance, does not file modelo 720 [7].

What changed after the EU Court of Justice ruling and Ley 5/2022

In its ruling of 27 January 2022 in case C-788/19, the EU Court of Justice (Tribunal de Justicia de la Unión Europea) found certain elements of the Spanish modelo 720 regime incompatible with EU law [3]. Spain responded with Ley 5/2022 of 9 March 2022. It rewrote additional provision 18 of the LGT (which still contains the list of information to report), changed article 39 of Ley 35/2006 on unexplained gains and repealed additional provisions 1 and 2 of Ley 7/2012 [3][5].

How the new rules apply to returns for past years depends on the circumstances of the case.

What penalties apply now?

According to AEAT, after Ley 5/2022 articles 198 and 199 LGT and articles 14 and 15 of Real Decreto 2063/2004 apply, and penalties are calculated separately for each of the three obligations [8]. For reference, below are the amounts from the text of these articles. These are general rules; a tax adviser can assess how the inspectorate will apply them in your case.

What counts as an “item of data” and a “set of data” is defined in articles 42 bis, 42 ter and 54 bis themselves: for accounts, a set of data is the information on the bank and on an individual account, and each date and each balance is an item of data [1].

What to prepare in advance: a checklist for clients from Russia and the CIS

• A list of all accounts abroad, including brokerage and savings accounts, with opening and closing dates. The balance on 31 December and the average balance for the fourth quarter.
• Statements for securities and fund units, documents for insurance policies with a surrender value and for annuities.
• Real estate abroad: address, acquisition date and value. If you sold it during the year, the sale price and date.
• Documents showing that you were a beneficiary, authorised person or holder, if you are not the sole owner.

Article 42 bis does not say how to convert balances in roubles, tenge, Belarusian roubles, hryvnias and other currencies into euros. For securities, article 42 ter, point 6, refers to the valuation rules of the wealth tax law [1]. Check the method with a gestor before filling in the form.

Common mistakes

• Calculating the threshold on the total of all assets. It is calculated separately for each of the three groups [1].
• Not filing because the balance on 31 December is below €50,000, although the average balance for the fourth quarter is above it. Exceeding either of the two figures is enough [1].
• Forgetting an account closed during the year. The obligation extends to those who stopped being the owner before 31 December [1].
• Forgetting that a beneficiary or authorised person on someone else’s account also files [1].
• Assuming that modelo 720 replaces the income tax return, or the other way round [10].
• Including cryptocurrencies in modelo 720: they go on modelo 721 [9].
• Relying on old material about the €5,000 and 150% penalties: after Ley 5/2022 the regime is different [3][4].

When you need an individual review

A review is needed if you became a tax resident in the middle of the year, if you have accounts and assets in several countries, if you are a beneficiary of someone else’s account or the property is jointly owned, if you previously did not file the return although your assets were above the threshold, or if you are choosing the article 93 regime. What exactly to file and at what valuation is for a tax adviser to determine.

How we can help

We do not give tax opinions. The ReloVictory team in Barcelona helps you put together a list of foreign assets with statements and documents for them, prepare questions for a tax adviser and fit this return into the rest of the tax side of your move. First consultation: 15 minutes free; full consultation: €121 for 45 minutes. Book here: consultation. Service page: digital nomad residence permit; step-by-step guide: DNV route card.

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ReloVictory · Sources reviewed 02.10.2026 · Not a substitute for individual legal advice.